Introduction
One of the most innovative and ambitious components of
India's Digital Personal Data Protection Act, 2023 (DPDP Act)
and the DPDP Rules, 2025 is the introduction of Consent Managers, a
category of regulated, independent intermediaries responsible for
enabling users to manage consent across platforms.
Unlike GDPR which relies on controllers and processors to manage
consent flows and unlike the US frameworks that rely largely on
opt-outs and do-not-sell registries, India has conceptualised a
federated, interoperable consent ecosystem where users may
centralise, monitor, modify, and withdraw consent through trusted,
neutral intermediaries.
Rule 4 of the DPDP Rules creates the legal and operational
backbone of this system, prescribing registration requirements,
governance obligations, technical standards, platform
interoperability, and regulatory oversight by the Data Protection
Board (DPB).